For those who are interested in this process where NMFS, CDF, CDFG, and NCRWQB have brought serious issue on this THP - a THP residing entirely in a flood plain of the Gualala River - and where the THP proponent, Gualala Redwoods Inc., have not addressed such concerns raised with appropriate mitigation, and where CDF has denied approval of such THP; the issue is wether the Board of Forestry will sustain this denial.
I have provided and overview and short summary of the agency comments raising issues. Those interested in making comment to the BOF may gain some insight into the issue for making factual basis.
OVERVIEW
The THP consists of 181 acres residing in the flood plain, lower reaches of the North Fork Gualala River just of few miles upstream from the estuary. Trees marked for cut reside in the flood plan and the Water Course Protection Zone. The ground is not steep, but is moderately sloped and is subject to impacts from past logging, erosion, and erosion impacts from activity further up the watershed. In fact, in excess of 10,000 acres of the upper North Fork Gualala River Watershed had been previously logged by the now infamous Coastal Forestlands. The activity was so intense much of the ground saw logging activity 2 or 3 times in a ten year period. 60% of the Planning Watershed has been logged in last 10 years, with over 80% of the whole sub-basin having seen logging activity in the recent past (10 to 14 years). Logging intensity of such magnitude that had never before been seen on the north coast leaving the conifer stand with less than 4,000 board feet per acre of standing inventory (Mendocino County average is about 11,000 bf/a), with roads in disrepair, and accelerated erosion from such activity now affecting the area in question. This all happened under the current Forest Practice Rules under the supervision of the California Department of Forestry.
All agency reviewing this THP has noted such impacts, continuing or ongoing, and has raised serious issue regarding approval of the THP as originally written and as modified.
It should be noted that CDF based their denial on issue raised by the National Marine Fisheries Service. Substantial issue raised by CDFG, and NCRWQCB were not part of the Denial. All relevant issue in the administrative record should, and must, be included in denial arguments. It has occured many times previously under similar circumstances when issue was raised, the THP(s) in question were modified objections of NMFS and other managing agencies. In this case such modification has not been manifested.
The Following is a summary of Agency Documents in the Administrative Record:
National Marine Fisheries Service, THP 1-00-101 MEN, July 30, 2001, & June 27,2000
. Forest Practice Rules and their administration must insure that activities do not result in take. Noted that NMFS and others (SRP Report, EPA, Dune Report) indicated the under the FPRs the WLPZ needed increased protections.
. Coho and steelhead presence.
. 303 (d) listed and sediment impaired river.
. Noted amount of disturbance (see figures above) in general area to be a concern - a significant amount of activity in a compressed time frame.
. THP resides in riparian strip median, 148 acres of WLPZ cut, in the 20 year flood plain (more likely 10 year flood plain). Noted flood plain riparian connectivity and disruption of Riparian Function. The THP included the Standard Protection of maintenance of 75% of existing overstory of which 25% is to be conifers. NMFS states such protections were not sufficient in this case. Remember: maintaining 75% overstory means leaving 75% of what is currently existing, which could mean substantially less than 75% overstory is extant.
. Noted ongoing and existing road/sedimentation problems with existing WLPZ and floodplain roads.
North Coast Regional Water Quality Control Board, THP 1-00-101 MEN, July 18,2000
. Concern the entire THP is in the floodplain.
. Questioned Erosion Hazard Rating Index - index should show higher rating due to level of disturbance from previous harvesting and disturbance level suggesting that additional precaution or protection be put in place.
. Noted exceptions to the FPRs (this is a common practice) for WLPZ activity and use of roads and skid trail in the WLPZ. Stated that such exceptions were not sufficiently justified (also a common practice) nor appropriately mitigated (also a common practice).
. Noted stream temperature considerations and need for more canopy to be retained that specified in the THP.
. Noted concerns for LWD and LWD recruitment. Noted likely trees for LWD recruitment were marked for cut, including some on the stream bank and of the largest size class.
. Noted aggredation in area from erosion in the Planning Watershed and areas upstream.
. Stated WLPZ harvest is not justified given the current condition of the NF Gualala River.
. Noted Roads need improvement - in general. Need to fix roads and deal with land disturbance from road construction.
. Noted level of disturbance = 60% of the planning watershed logged in the last 10 years (1479 acres clear cut and 5654 acres clear cut by step silviculture). This does not take into account intense logging activity upstream that is continuing to exacerbate instream problems and should be considered in Cumulative Impacts.
California Department of Fish and Game, THP 1-00-101 MEN PHI Report, May 26, 2000
. Noted other dependant species in habitat type of this area - not just fisheries.
. Questioned LWD standards in THP 5 to 10 trees per 1000' of stream bank. Recommended 10 trees per 1000' of stream bank of upper 20% of the size class.
. Recommended wider flood zone marking, thus expanding WLPZ.
. Recommended 85% overstory retention for entire THP.
. Recommended raptor survey
. Recommended plant survey
I am not sure any of these CDFG recommendations were incorporated into the THP.
CDF Pre-Harvest Inspection Report, THP 1-00-101 MEN May 25, 2000, James Purcell
. Noted 1997 debris torrent contributing to sediment and aggredation problems.
. Noted Erosion Hazard Rating soils descriptions not accurate.
. Noted wet weather operating plans not sufficient (this is often the case and a common problem on THPs).
. Noted stream channels as a conduit for sediment and improper stream classifications.
. Noted bad road drainage - of the flood plain, WLPZ, road.
. Noted largest diameter trees marked for cutting.
. Noted problem with canopy cover assessment
. Stated " Project did not incorporate sufficient mitigations measures to ensure that the Cumulative Impacts from sediment will not occur."" Plan has significant potential for adverse effect.
Subsequent Adjustments to Modify the THP
Adjustment offered by Gualala Redwoods in attempt to bring the THP in compliance include the following:
. Offered 85% Canopy retention where closure is low. This resulted in some change in the cut marking. Some stream bank trees marked for cut would be retained.
. Offered some road and erosion control fixes beyond the original THP.
. Offered to review and fix WLPZ skid trails.
. Said NO to helicopter logging suggestion.
Conclusions
I think the concerns speak for themselves. I believe this plan was put out as a test of both NMFS and CDF, as well as the other agencies. Gualala Redwoods has not submitted sufficient mitigations to justify approval of this THP.
Areas that show low closure should not have any harvesting allowed at all.Retaining 25% of overstory in conifers is not sufficient for healthy riparian function. The 85% retention suggestion for such areas does not fit the mitigation needs that would be appropriate for this THP. In fact, such mitigation changes the THP very little. LWD retention standards need to be greatly increased allowing trees to naturally be recruited - with their rootwads.
The roads and skid trails are a mess and should be fixed, even if THP is not approved. This area of Gualala Redwoods Property is not in compliance with the Basin Plan.
There is no way this plan should be approved, unless it is substantially changed and most issue resolved. Given the facts this would be very difficult with the only possibility of a very light, non-invasive cut in areas that showed very good canopy closure - only. Then there is the problem of fixing the roads and other erosion problems.
Alan Levine
Coast Action Group
Box 215
Point Arena, CA 95468
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